Suspicious Activity Reporting (“SAR”) forms the cornerstone of the Bank Secrecy Act (“BSA”) reporting system. Broadly speaking, federal regulations require all banks and financial institutions to […]
This is the third of four articles that will use the case to examine card-not-present fraud from a legal perspective. Part 1 described the case and […]
Recently, the criminal case against online merchant Jeremy Johnson in Utah that started back in June 2011 finally came to a close. After more than four […]
In November 2015, the Federal Trade Commission (“FTC”) reported its spearheading of a nationwide crackdown (known as Operation Collection Protection) along with more than 70 federal […]
Department of Justice introduced Operation Choke Point in early 2013 as an enforcement initiative to choke off swindlers’ access to the payments system by targeting the […]
Little more than a year ago, the United States Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued written guidance to banks for extending merchant services to […]
The day has finally arrived: The federal government has decided to make payment processors and ISOs completely (and ridiculously) responsible for the “sins” of their merchants. […]